DAQ-2024-007286

State of Utah
SPENCERJ. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor
Department of
Environmental Quality
Kimberly D. Shelley
Executive Director
DryISION OF AIR QUALITY
Bryce C. Bird
Director
November 6,2023 DAQC-I 168-23
Site ID 15738 (B1)
Sent Via Certified Mail No. 70190700000208346160
Lauren Brown
XCL Resources, LLC
3217 Montrose Boulevard #200
Houston, TX77006
Dear Ms. Brown,
Re: Compliance Advisory - XCL Resources, LLC - Butcher Butte Pad27-4D-23,
Duchesne County
On September 28,2023, a representative of the Utah Division of Air Quality (DAQ) conducted an
inspection of XCL Resources, LLC Butcher Butte Pad27-4D-23located at latitude 40.273693,
longitude -l 10.200244, Duchesne County.
The DAQ observed the following potential violations of the following regulations:
R307-506-4 - Storage Vessels
R307-509-4 - Leak Detection and Repair
R307-51l-4 - Associated Gas Flaring
R307-501-4 - General Requirements
R307-508-3 - VOC Control Devices
These findings may be a violation of Utah Air Conservation Rules. XCL Resources, LLC Butcher
Butte Pad27-4D-23 is required to comply with the above regulations. A written response to this
letter is required within ten (10) business days of receipt of this letter.
195 North 1950 West. Salt Lake City, UT
Mailing Address: P.O. Box 144820. Salt Lake Ciry, Lrf 84114-4820
Telephone [phone] . Fax [phone]. T.D.D. [phone]
w.deq.utah.gov
Printed on 100% recycled paper
DAQC-I168-23
Page2
Additional details about the above observations and regulations are included with this letter.
Please contact Stephen Foulger at [phone] or [e-mail] if you have any
additional questions.
Rik Ombach
Minor Source Oil and Gas Compliance Section Manager
RO:SF:rh
cc: TriCounty Health Department
Alan Humpherys, UDAQ, MinorNSR Section Manager
DAQC-I168-23
Page 3
Potential Violation(s)
On September 28,2023, an inspector from the DAQ attempt'ed an inspection at XCL Resources,
LLC Butcher Butte Pad27-4D-23 located at latitude 40.273693,longitude -110.200244,
Duchesne County.
At the time of the inspection, the DAQ documented the following potential violation:
Requirement & Rule Comments & Observations
Initial monitoring surveys were within 60 days after startup for
new sources. Subsequent surveys are semi-annual forregular
components, annual for difficult-to-monitor components, and as
required by the monitoring plan for unsafe-to-monitor
components. [R307-509-4( I Xd)]
XCL failed to produce requested records.
The source has an emissions monitoring plan.
|-R307-509-4( I Xa)l
XUL talled to produce requested records.
The following records are kept:
VOC control device efficiency, for life of the equipment
Manufacturer operating and maintenance instructions for VOC
control devices, for life of the equipment
AVO inspections of the VOC control device(s), associated
equipment and any repairs, for 3 years. [R307-508-41
XCL failed to produce requested records.
Resurvey of the repaired components is completed within 30
days. f R307-s09-a( 1 Xe)l
XCL failed to produce requested records.
The monitoring plan addresses difficult-to-monitor and unsafe-
to-monitor components. fR307-509-4( 1 Xb)l
XCL failed to produce requested records.
The following records are kept:
The time and date of event
Volume of emissions
Any corrective action taken for 3 years.
1R307-sl l-s(1XaXb)l
XCL failed to produce requested records.
Monthly AVO inspections are conducted on VOC control
devices and associated equipment, and corrective actions are
taken within 15 days. fR307-508-3(3)l
XCL f-ailed to produce requested records.
If emissions control is required, monitoring surveys are
conducted to observe each fugitive emissions component for
tugitive emissions. [R307-5094( 1)(c)l
XCL failed to produce requested records.
The following records are kept:
The emissions monitoring plan, for life of the site
LDAR inspections, repairs and resurveys, for 3 years
|-R307-s09-st
)(UL talled to produce requested records.
Fugitive leaks are repaired within 15 days unless infeasible,
unsafe, etc., as stated in the rule, which require repair withitrz4
months per the rule. 1R307-509-4(l)(fl]
XCL failed to produce requested records.
Records for each of the following are kept for three years:
Storage vessel vent system inspections (openings, thief
hatches, pressure relief devices, bypasses, etc.), if required
XCL failed to produce requested records.
Monthly crude oil throughput
Emission calculations, actuals and sampling data when used to
justify an exemption to storage vessel rules
Emergency storage vessel usage (dates used, emptied, and
volumes). if not controlled oer R307-506-4(2)1R307-506-5.l
VOC emissions are minimized as reasonably practicable by
equipment design, maintenance and operation practices.
[R307-s014(1)]
Two produced water thief hatches, five
pneumatic controls, and two three-inch
90-degree gas lines found leaking
emissions at the time of inspection.
Air pollution conkol equipment is designed and installed
appropriately, maintained and operated to control emissions.
IR307-s014(2)]
Two produced water thief hatches, five
pneumatic controls, and two three-inch
9O-degree gas lines found leaking
emissions at the time of inspection.
DAQC-l t68-23
Page 4
The purpose of a Compliance Advisory (CA) is to document observations made by the DAQ. You
are responsible for complying with the Utah Air Conservation Rules. There are possible
administrative and civil penalties for failing to do so. Section 19-2-115 of the Utah Code
Annotated provides that violators of the Utah Air Conservation Act and/or any order issued there
under may be subject to a civil penalty of up to $10,000 per day for each violation.
When considering if the potential violation(s) are resolved, the DAQ will consider the written
response to this CA. Responses may include information demonstrating compliance with the
regulations or an anticipated schedule from your company to become compliant with the
applicable regulations. Once received, the DAQ will review your response and the CA may be
revised as a result of that review.
Failure to respond in writing within ten (10) business days of receipt of this CA shall be
considered in the escalation of subsequent enforcement action and assessment of penalties.
Possible DAQ actions to resolve a CA include: No Further Action Letter, Warning Letter, Early
Administrative Settlement with reduced civil penalty, Settlement Agreement with civil penalty, or
Notice of Violation and Order to Comply
This CA does not limit or preclude the DAQ from pursuing additional enforcement options.
Additionally, this CA does not constitute a bar to enforcement action for conditions that the DAQ
did not observe or evaluate, or any other conditions found during future inspections.
A meeting may be requested to discuss this CA. Please contact Stephen Foulger at [phone]
or [e-mail] if you would like to request a meeting or if you have any questions.
ilililililil
1510 1q0e ?131,
USPSTRACKI{G#
r+{ ll I
Flrct-Class Mail
Postage& Fees PaH
USPS
P6mitNo. G,10
C\'Ocu
o)
c!
Oz.
J
ztu
=ZoG
a
uJ
!
5
AH DIVISION OF AIR QUALITY J
CE SECTION
BOX 14482A
&rr LAKE crry uT 841 t4-4s20
)
I GomPlete items 1,2, and 3'
r Pdnt vour name and address on the reverse
sJ tnit we can return the card to you'
r Attach this card to the back of the mailpiece'
or on the front if space permtts:-------
-trnulfiillilnll ffi lullm llltl lllll I lll
9590 9402 7931 2305 6414 s0
ffiidefr umuerEansrer from service
?01,5 E?0u uE0e IlE3!{ 833?
I PS F"* 38Tfiury 2020 PsN 7630-02-000-s053
DJ" d"li".ty "ddt
* different fiom item 1?
- u*--gS. enter delivery address below:
C. Date of Delivery
t^
Yes
Notlt:,i*: .1
EtrG3eS
.j ceTYPe
^--.|.iiqnature
Adult Slgnature Hesttlctgd Ddlvory
Mail@
Ecitim.a uat n""ttcted DeltueIY
t] Collecton Deltuery
E coiiea on oetivervREstrlcted Dellvery
lnsurod Mall
insured Mall Restdc'ted DEltusrY
r\lmr
rrl
.-E
t
m
EOE
ru
trl
EtE
E
E]
ru
Ef
IT
r-lEr!
DRO.c- tl6g-23
: Please prlrtlour name, address,
Domestic Retum Receipt
\\1 15123
Postrnaft
Hera
DAUc- tl6s-23
tr PriorltY Mail ExPress@
t] Rooistered MaIFH
U Registorod [Iait nestlcted
Deliven
E Sionatrlre Gonfirmatlonn
E Signaturs Conlirmatlon
Bestic{ed Dellvery
r,[,rllduiltillhthll,l,ltl,,,tl ttl,,ttt,illtltlrtrlI rllr t,l
J.Art'role Addressed to:
-LAL'RffiBRO\\N h;*
xii,p-sou*cEs - - #-.,,
Aon NORIH SHEPARD DRTV€. SUI
f,'8,xffi;x'i,ffi--",$
(hadopy) $ .-
Elnetumn@Fr(a€cbnlc) $-
Elcqilfied Mail R€6trlc1ed D€ilvery 6
-
ElAduftSlgnatuBRoqulrcd $-Slgnat@ Hoqu@
Slgnatr€ Beltic.t€d D€ltu"al .-
LATIREN BROWN
XCL RESOURCES
600 NORTH SMPARD DRIVE, SI.IITE 390 "--
HOUSTON,TX 77007-4580
FI o v)p (D H,
A'
nHi Ez(/
)
rr
j
fr
rr
,Flr
,a E'
v)*l
lr
l
a
Ll
5
z3
E-
H
E
F
Es
S
E
E
ES
T
F
-
E
i
=E
F
;
t
t-
F
oo

FI
E
ts

*=
{
-
u
rr
-
-
-_
E
-
-
U-
-tv-Ef
-
lJ
-
---
u-El
-
-
I-
t
-
nt
-
u-Or

----
TTu-
-
o
FI
R
l
H
4
E
l
G
f
7)
e)2-
_
(^Y C.
J
t"
J
ql A l-lr .&
IJ
!r

Tt
-
.

Ln
3
*6
1
H
rE
f
l

rr
I
I
E(
f
,
z
,

(u
E$
u
l
{
lO

rr
r

(,
ot
1
y
'
t
J
\
tJ
1

lr
wm
l
r
tgeo
\l l\
re
rt
,
Sl
d
{J
.
..

I
-;
l
t,
'
ft
i

'
-:
-
r$
l
l,
.
l
.
r

";
rl
l

-:
.l
i.f
*
=

*
_n
i
l
t

::
,
tI
!
o U)5z o-r
l >n o J{
XE
rq aq
9w
Li

it
r
fr
'
t
^si
t-t-o
(J
)N)
-l?oz-lFo(t
)
rn EDoet-
rn F U+N)O
rr
'

.'
:rtE,
ff
i
"T
:
ff
i
r
)<11t-
z,
t
cr
J
{t
r
El
l
f
ro
cr
n
?s
f
i

(o
Fr
-
{

Jr
tr

fr
i

E:

1,
t-

af
l
ml
z

z.
Eg
(
f
;[
;

^
0?
0
u

0E
E
e

88
3
'
{

bl
,
E
I
I
?u
1
,
1
:E

9.
1

X
t-
P=
P
E
E<
e
E
oQ
,
)
i
Z
Z4
0
W
".
=
c
r
E
aa
a
?
sr
'
1
f
i
z
OC
E
-
oA
t
O,

:U

t-
F.
)
rn FU ++N)oO
OO
N

ri
e
\
?r
.
r
t

l)
-
q
E
-r

co

=t
'
\
o=
l
-

..

I
'i

;
fr
H
#
J
f
h-
'
L
I
<n

i,

[,
r
E
n
E
e"
[
l
B
[
-
O
')
q
\
:i

m
[F
r
,
ti
H
t
i
,,

(J
t

l:
$
[
f
,
(.
-
)

l.
l
:
f
l
'.
i
t
r
I I
EI
t!
:i
l HITI>tnl
-l
t<t
rl oi
_t
,mlzt<
trITlolzl<
lmlz tn
l5
t-l>lrll
!3vI t-3 E.E
tr
t
r
o,
=5o,EE
;sgc dc
8C Bo
E €
tr o a@ 5,II
tr E a €a II g,o .?
=o6-CJw
v I c)t 6-
oO
I nr